Swiss Financial Market Supervisory Authority FINMA
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PolyReg General Self-Regulatory Organisation
 
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Sanctions of the Federal Council

The Federal Council has ordered sanctions against various countries by ordinance based on the Embargo Act. SECO is responsible for enforcement. Some of these sanctions are also directed against organisations and individuals and include an obligation to report to SECO and a permanent freeze on assets. The applicable sanction ordinances exist independently of the obligations under the AMLA. The current status can be found on the SECO websites.

Sanctions of the FATF

The FATF maintains a "black list" of various countries that show significant strategic deficiencies in the fight against money laundering and calls for increased diligence in dealing with these countries. Transactions and business relationships in connection with these countries are subject to the special duty of clarification (§31 in connection with §32 para. 4 and §33 para. 2 of the Regulations of SRO PolyReg).

Furthermore, the FATF maintains a "grey list" of countries that actively cooperate with the FATF to address strategic deficiencies in their anti-money laundering regulations. These countries are subject to increased monitoring, which may be an indication of the special duty of clarification (§31 in connection with §32 para. 1 and §33 para. 1 of the Regulations of SRO PolyReg).

Country risk classification

In addition to the FATF lists, the country lists below are a practical tool for evaluating the increased geographical risks of a business relationship, unless the financial intermediary has established other criteria in application of §32 para. 2 of the Regulations, taking into account its specific business activity and the associated risks. Since the lists are not based on the same criteria, cumulative use is recommended: